The Taxation (Annual Rates for 2026–27, FBT Simplification, Foreign Investment Funds, and Remedial Measures) Bill (the Bill) was introduced on 10 September 2026.
Amendments to the Income Tax Act 2007 proposed in the Bill include:
- effective from the 2028-2029 and later income years a requirement that private trusts that allocate beneficiary income to tax exempt entities to pay the amount into an account (with a financial institution) of the tax-exempt entity within a specified time for that income to be exempt.


- an amendment to provide that trustees do not need to obtain the Commissioner of Inland Revenue’s approval for a beneficiary to undertake the trustee’s tax duties, such as providing returns, making assessments and satisfying income tax liabilities. This would align with current practice. A clarifying amendment would also provide that the trustee and beneficiary would remain jointly and severally liable for this tax
- expanded access to the revenue account method (RAM) to all natural persons or eligible trustees, irrespective of when they arrived in New Zealand. This puts access to the RAM on the same footing as other FIF calculation methods in respect of unlisted shares
- an amendment to align the cash basis person requirements for deceased estates with that of other taxpayers by repealing section EW 60 of the Income Tax Act 2007. This would mean that if financial arrangements (arrangements) in a deceased’s estate fall below the cash basis person thresholds, trustees can account for those arrangements on a cash basis without further restrictions.
- an amendment to allow resident withholding tax (RWT) on dividends to be deducted at 39% if the payer and the recipient agree.

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